Standing out among a flurry of new post-trial paperwork filed Friday in the Apple v. Samsung docket is Apple's succinct response to Samsung's blame-the-jury-foreman strategy. Samsung's "attack on the jury" is "clearly unfounded," Apple lawyers write, and the group believes US District Judge Lucy Koh should reject the Korean company's request for a new trial.

Samsung said the jury foreman, Velvin Hogan, wasn't truthful about his history of litigation with Seagate, his former employer. Since Samsung recently became a major Seagate shareholder (buying 9.6 percent of the company), that was an important fact to disclose. Samsung could have used a strike to kick him off the jury.

"All the information Samsung got about Hogan after trial, however, it could have dug up during trial. Had Samsung [asked Hogan about Seagate], or ordered the bankruptcy file—the exact step it took only after it received the unfavorable jury verdict—it could have discovered the Seagate complaint," wrote Apple lawyers in their new brief on the subject. "By doing nothing, Samsung waived its objections."

In any case, Hogan was hardly dishonest. He described a 2008 lawsuit and was never asked in court about others, or about his bankruptcy, "and hence never failed to answer a question truthfully."

Apple tries to portray Samsung's argument for a new trial as a major reach. "[Samsung's] theory is that, due to a decades-old dispute with Seagate, Mr. Hogan lied to serve on the jury in a case where Seagate is not a party in order to exact revenge by harming a Seagate shareholder," Apple lawyers note. "This falls far short of establishing challenge for cause."

As for Hogan's comments to the media in post-trial interviews, Apple says his comments about intellectual property were "balanced, not biased." He instead emphasized that jurors wanted to protect intellectual property rights "no matter who they belonged to."

(I usually steer clear of making predictions in litigation. If the outcome of this case were predictable, it probably wouldn't have gone to a trial. But in this case, I find it hard to believe Samsung's "blame the juror" arguments are going to make much headway with Judge Koh. She was willing to let a current Google employee on the jury, so it's hard to believe she would be inclined to find fault with the jury foreman because of an ancient conflict with Seagate. It's a company that is far more tangential to this case than Google.)

Samsung pleads: Keep our phones on the market, no more damages

Samsung filed its own motions on Friday, trying to shoot down Apple's request for an additional $535 million in damages on top of the $1.05 billion it was awarded by the jury verdict. If that verdict stands up on appeal, it will be the largest patent verdict in history. Even more importantly, Samsung wants to avoid facing a court-ordered injunction that could kick some of its phones off the market.

The company reemphasized a point it made at trial: Apple's design patents aren't the key factors driving consumer demand for its phones. Samsung also argues that Apple can't be hurt too badly by infringement of these patents, since it doesn't even use the designs and trade dress at issue in the trial. Those are more connected to the iPhone 3 and 3GS—old phones Apple doesn't make anymore. (Apple disagrees with that point, saying the iPhone 4 and iPhone 4S do use the trade dress and patents at issue.)

If Apple is able to block its phones from going to market, it would go beyond hurting its competitor—the public interest will be harmed, argues Samsung.

"The public has an overwhelming interest in preventing one company from having a monopoly over
basic elements of smartphone design such as a rectangular shape with rounded corners," Samsung lawyers argue. "This litigation is part of Apple’s campaign against makers of Android devices, which provide free, open source mobile software that any developer can use to create applications for mobile devices and that any handset manufacturer can install on a device. This Court should not deprive consumers of choice by granting the broad, vague injunction that Apple seeks."

Plenty of dumb on both sides here, if you ask me. Apple's comments re: the foreman are correct, but they conveniently ignore how he allegedly used an incorrect understanding of patent law and prior art, which was as I recall the other major part of Samsung's motion. As for Samsung, I don't think it's relevant that an injunction harms consumers by depriving them of choices - if you cheated when you made your phones, then those were choices that never should have been given to the public in the first place. Honestly, I'm not sure which side is less sympathetic in this case anymore.

"I was thinking about the patents, and thought, 'If this were my patent, could I defend it?'" Hogan recalled. "Once I answered that question as yes, it changed how I looked at things."

The jury "wanted to send a message to the industry at large that patent infringing is not the right thing to do, not just Samsung," Hogan told the newspaper. "We felt like we were 100 percent fair, but we wanted something more than a slap on the wrist."

Another juror, Manuel Ilagan, confirmed to CNET that Hogan's influence on the jury was significant. "He had experience," said Ilagan. "He owned patents himself... so he took us through his experience. After that it was easier."

Prior article paints a decent picture of jury problems. Maybe they were genuine and objective in reaching the verdict, but this 'sending a message' mentality makes it sound like someone had an axe to grind.

Judges question:"THE NEXT QUESTION IS, HAVE YOU OR A FAMILY MEMBER OR SOMEONE VERY CLOSE TO YOU EVER BEEN INVOLVED IN A LAWSUIT, EITHER AS A PLAINTIFF, A DEFENDANT, OR AS A WITNESS? "

Hogan's response starts on the very bottom of page 7. It's a thorny issue really. He starts by describing the 2008 case and answers several questions from the judge. The judge then never asks if there were other lawsuits, or if he was a witness anywhere else. Additionally at the end, Hogan never speaks up and adds that he has had other lawsuits.

From my point of view, Hogan is ethically wrong in that he should have mentioned all the lawsuits. However, I'd say in the end that he gets a pass based on the way that question is worded.

"I was thinking about the patents, and thought, 'If this were my patent, could I defend it?'" Hogan recalled. "Once I answered that question as yes, it changed how I looked at things."

The jury "wanted to send a message to the industry at large that patent infringing is not the right thing to do, not just Samsung," Hogan told the newspaper. "We felt like we were 100 percent fair, but we wanted something more than a slap on the wrist."

Another juror, Manuel Ilagan, confirmed to CNET that Hogan's influence on the jury was significant. "He had experience," said Ilagan. "He owned patents himself... so he took us through his experience. After that it was easier."

Prior article paints a decent picture of jury problems. Maybe they were genuine and objective in reaching the verdict, but this 'sending a message' mentality makes it sound like someone had an axe to grind.

If that dude wouldn't have opened his mouth this could have actually been over with. Samsung is in the right because that guy made a decision and did it with bias and influenced other jurors to follow. Samsung does have a right to a fair trial and because of tards like this guy tons of money and time get wasted only to further benefit the lawyers. No matter the outcome neither samsung or apple are the victors.

"I was thinking about the patents, and thought, 'If this were my patent, could I defend it?'" Hogan recalled. "Once I answered that question as yes, it changed how I looked at things."

The jury "wanted to send a message to the industry at large that patent infringing is not the right thing to do, not just Samsung," Hogan told the newspaper. "We felt like we were 100 percent fair, but we wanted something more than a slap on the wrist."

Another juror, Manuel Ilagan, confirmed to CNET that Hogan's influence on the jury was significant. "He had experience," said Ilagan. "He owned patents himself... so he took us through his experience. After that it was easier."

Prior article paints a decent picture of jury problems. Maybe they were genuine and objective in reaching the verdict, but this 'sending a message' mentality makes it sound like someone had an axe to grind.

Yeah, admitting you have personal stake in the outcome of a case by the precedent it sets would never interefere with a fair decision.

"I was thinking about the patents, and thought, 'If this were my patent, could I defend it?'" Hogan recalled. "Once I answered that question as yes, it changed how I looked at things."

The jury "wanted to send a message to the industry at large that patent infringing is not the right thing to do, not just Samsung," Hogan told the newspaper. "We felt like we were 100 percent fair, but we wanted something more than a slap on the wrist."

Another juror, Manuel Ilagan, confirmed to CNET that Hogan's influence on the jury was significant. "He had experience," said Ilagan. "He owned patents himself... so he took us through his experience. After that it was easier."

Prior article paints a decent picture of jury problems. Maybe they were genuine and objective in reaching the verdict, but this 'sending a message' mentality makes it sound like someone had an axe to grind.

Making a devil's advocate argument here, not saying Apple was in the right, nor saying that Samsung in the wrong, just musing about the juror here:

What if the jury "of ones peers" should include a representative amount of patent holders? I believe that would be one or two jurors then.

What if the jury "of ones peers" should be peers of the defendant and accuser? I believe in that case most in the jury ought to be patent holders.

And why shouldn't the juror have some interest in the verdict? Assume for a second a black guy in the sixties in the jury a civil trial regarding racial discrimination, would that guy be barred from sending a message because he obviously had a vested interest in the outcome of the trial?

Judges question:"THE NEXT QUESTION IS, HAVE YOU OR A FAMILY MEMBER OR SOMEONE VERY CLOSE TO YOU EVER BEEN INVOLVED IN A LAWSUIT, EITHER AS A PLAINTIFF, A DEFENDANT, OR AS A WITNESS? "

Hogan's response starts on the very bottom of page 7. It's a thorny issue really. He starts by describing the 2008 case and answers several questions from the judge. The judge then never asks if there were other lawsuits, or if he was a witness anywhere else. Additionally at the end, Hogan never speaks up and adds that he has had other lawsuits.

From my point of view, Hogan is ethically wrong in that he should have mentioned all the lawsuits. However, I'd say in the end that he gets a pass based on the way that question is worded.

This. Based on everything that has been released to the public, Hogan at the very least evaded answering questions he was sworn in to answer, given the nature of the oath sworn when delivering testimony before the court, this means Hogan could be considered to have perjured himself. Whether this would be considered grounds for an appeal is up to the appeals circuit to decide, but considering that they've reprimanded Koh and the legal teams twice already, they seem to be waiting for it.

Judges question:"THE NEXT QUESTION IS, HAVE YOU OR A FAMILY MEMBER OR SOMEONE VERY CLOSE TO YOU EVER BEEN INVOLVED IN A LAWSUIT, EITHER AS A PLAINTIFF, A DEFENDANT, OR AS A WITNESS? "

Hogan's response starts on the very bottom of page 7. It's a thorny issue really. He starts by describing the 2008 case and answers several questions from the judge. The judge then never asks if there were other lawsuits, or if he was a witness anywhere else. Additionally at the end, Hogan never speaks up and adds that he has had other lawsuits.

From my point of view, Hogan is ethically wrong in that he should have mentioned all the lawsuits. However, I'd say in the end that he gets a pass based on the way that question is worded.

He answered the question that was asked. That's not unethical behavior. If the judge or lawyers had wanted to know more, they should have asked about it. They don't have unlimited time to go over every single detail of every prospective juror's entire life history.

He didn't answer as asked. He was asked "ever been involved" and later he said his omission was honest because the question was only the past 10 years. He lied.

He admits to directing the jury from the beginning and has also demonstrated that he incorrectly told them how patent law works. Given the jury also ignored directions for how to fill out the verdict, it is clear this trial is going to be granted an appeal.

And the judge also restricted the sides from laying out their full case because the judge knew it would go to an appeal either way just because of how much money is on the line.

He didn't answer as asked. He was asked "ever been involved" and later he said his omission was honest because the question was only the past 10 years. He lied.

He admits to directing the jury from the beginning and has also demonstrated that he incorrectly told them how patent law works. Given the jury also ignored directions for how to fill out the verdict, it is clear this trial is going to be granted an appeal.

And the judge also restricted the sides from laying out their full case because the judge knew it would go to an appeal either way just because of how much money is on the line.

But no where in the questioning were the words "list all lawsuits you have been involved in." If the question doesn't ask for additional information, you don't give it. The question "have you ever been involved in" has the answer "yes." He didn't lie, he just didn't give the additional information that people thought he should have given despite the wording of the question.

"All the information Samsung got about Hogan after trial, however, it could have dug up during trial. Had Samsung [asked Hogan about Seagate], or ordered the bankruptcy file—the exact step it took only after it received the unfavorable jury verdict—it could have discovered the Seagate complaint," wrote Apple lawyers in their new brief on the subject. "By doing nothing, Samsung waived its objections."

- no, regardless of the jury's verdict and fact checking before or after, Samsung has a right to a fair trial, or does Apple have a patent on that to?

Judges question:"THE NEXT QUESTION IS, HAVE YOU OR A FAMILY MEMBER OR SOMEONE VERY CLOSE TO YOU EVER BEEN INVOLVED IN A LAWSUIT, EITHER AS A PLAINTIFF, A DEFENDANT, OR AS A WITNESS? "

Hogan's response starts on the very bottom of page 7. It's a thorny issue really. He starts by describing the 2008 case and answers several questions from the judge. The judge then never asks if there were other lawsuits, or if he was a witness anywhere else. Additionally at the end, Hogan never speaks up and adds that he has had other lawsuits.

From my point of view, Hogan is ethically wrong in that he should have mentioned all the lawsuits. However, I'd say in the end that he gets a pass based on the way that question is worded.

It seems he was telling the truth, but not necessarily the whole truth. There were other truthful answers he could have given to the question (in addition to the one he gave) which would have been relevant to the case. Deliberately misleading omission is just as much a form of lying as direct falsehoods. The wording may be ambiguous enough to protect him from a criminal perjury charge, but I think it should absolutely be cause for a new trial (I'm not predicting it will, I just think it should be).

He didn't answer as asked. He was asked "ever been involved" and later he said his omission was honest because the question was only the past 10 years. He lied.

He admits to directing the jury from the beginning and has also demonstrated that he incorrectly told them how patent law works. Given the jury also ignored directions for how to fill out the verdict, it is clear this trial is going to be granted an appeal.

And the judge also restricted the sides from laying out their full case because the judge knew it would go to an appeal either way just because of how much money is on the line.

But no where in the questioning were the words "list all lawsuits you have been involved in." If the question doesn't ask for additional information, you don't give it. The question "have you ever been involved in" has the answer "yes." He didn't lie, he just didn't give the additional information that people thought he should have given despite the wording of the question.

He admits he omitted information and said he only omitted because the question was limited to ten years, which it wasn't. That is a lie.

Then the follow-up question is whether or not his lawsuit experience would affect his ability to be impartial. Not speaking up here that he an axe to grind with Hitachi, which is now owned by Samsung is clearly being dishonest.

Combine the fact that he lied to get on the jury and then brags today and strong-arming the jury to sending a message to Samsung is plenty of reason to grant an appeal.

He didn't answer as asked. He was asked "ever been involved" and later he said his omission was honest because the question was only the past 10 years. He lied..

You're right.

Hogan lied. A lie by omission, but a lie all the same. Hogan claims he was only required to list lawsuits from the past ten years, yet another lie.

By the instructions given, Hogan was required to list all lawsuits, not just those of the past 10 years. He clearly did not comply with the instructions in voir dire. Is it possible Hogan honestly misunderstood the instructions? Of course, but it still means he didn't tell the truth and Samsung was not given information they could have used to disqualify Hogan from the jury.

Will Judge Koh throw out this verdict based on the jury foreman's lies? It would certainly be the proper decision, but since it would show that Koh failed to do her job properly, it seems doubtful.

Unlike Koh, the appellate court doesn't have any skin in this game, so expect them to tee off on Hogan's head and send the whole thing back for an entirely new trial. That will reset the clock for at least another year, so assuming there's no settlement, this case won't pass its final appeals for another three years, perhaps longer.

"I was thinking about the patents, and thought, 'If this were my patent, could I defend it?'" Hogan recalled. "Once I answered that question as yes, it changed how I looked at things."

The jury "wanted to send a message to the industry at large that patent infringing is not the right thing to do, not just Samsung," Hogan told the newspaper. "We felt like we were 100 percent fair, but we wanted something more than a slap on the wrist."

Another juror, Manuel Ilagan, confirmed to CNET that Hogan's influence on the jury was significant. "He had experience," said Ilagan. "He owned patents himself... so he took us through his experience. After that it was easier."

Prior article paints a decent picture of jury problems. Maybe they were genuine and objective in reaching the verdict, but this 'sending a message' mentality makes it sound like someone had an axe to grind.

Making a devil's advocate argument here, not saying Apple was in the right, nor saying that Samsung in the wrong, just musing about the juror here:

What if the jury "of ones peers" should include a representative amount of patent holders? I believe that would be one or two jurors then.

What if the jury "of ones peers" should be peers of the defendant and accuser? I believe in that case most in the jury ought to be patent holders.

And why shouldn't the juror have some interest in the verdict? Assume for a second a black guy in the sixties in the jury a civil trial regarding racial discrimination, would that guy be barred from sending a message because he obviously had a vested interest in the outcome of the trial?

The fact that he's a patent holder isn't the issue, and having a patent holder in this jury wouldn't be inherently bad. But his patents are a bit dubious (they're basically for a TiVo, filed several years after TiVo was out) and only look solid when you use a somewhat contorted definition of 'prior art', which he then applied to this patent case.As for having an interest in the outcome - no, they should not, juries should be impartial and set aside their biases. By your example, a white supremacist also should be allowed to be on the jury and send a message, because he also has a vested interest in its outcome.

The meaty part of it is not that Hogan lied during Voir Dire, but that he incorrectly applied outside information that was harmful to the jury decision. Not only was his explanation of Prior Art factually inaccurate, but he was specifically instructed to only use the law as presented by the court.

Judges question:"THE NEXT QUESTION IS, HAVE YOU OR A FAMILY MEMBER OR SOMEONE VERY CLOSE TO YOU EVER BEEN INVOLVED IN A LAWSUIT, EITHER AS A PLAINTIFF, A DEFENDANT, OR AS A WITNESS? "

Hogan's response starts on the very bottom of page 7. It's a thorny issue really. He starts by describing the 2008 case and answers several questions from the judge. The judge then never asks if there were other lawsuits, or if he was a witness anywhere else. Additionally at the end, Hogan never speaks up and adds that he has had other lawsuits.

From my point of view, Hogan is ethically wrong in that he should have mentioned all the lawsuits. However, I'd say in the end that he gets a pass based on the way that question is worded.

I don't know man. How can he be "ethically wrong" and still get a pass when he clearly didn't tell the *whole truth* when asked by the court officer "if he's EVER been involved"? Especially since he was only involved in a couple of cases, and the one case that had major consequences on his life is the case he decided to be quiet about?

Prior article paints a decent picture of jury problems. Maybe they were genuine and objective in reaching the verdict, but this 'sending a message' mentality makes it sound like someone had an axe to grind.

Making a devil's advocate argument here, not saying Apple was in the right, nor saying that Samsung in the wrong, just musing about the juror here:

What if the jury "of ones peers" should include a representative amount of patent holders? I believe that would be one or two jurors then.

What if the jury "of ones peers" should be peers of the defendant and accuser? I believe in that case most in the jury ought to be patent holders.

And why shouldn't the juror have some interest in the verdict? Assume for a second a black guy in the sixties in the jury a civil trial regarding racial discrimination, would that guy be barred from sending a message because he obviously had a vested interest in the outcome of the trial?

The fact that he's a patent holder isn't the issue, and having a patent holder in this jury wouldn't be inherently bad. But his patents are a bit dubious (they're basically for a TiVo, filed several years after TiVo was out) and only look solid when you use a somewhat contorted definition of 'prior art', which he then applied to this patent case.As for having an interest in the outcome - no, they should not, juries should be impartial and set aside their biases. By your example, a white supremacist also should be allowed to be on the jury and send a message, because he also has a vested interest in its outcome.

The sending a message (as I understood it from the link above) part was about whether Samsung should be given a slap on the wrist or harshly punished, so my devil's advocate questions should have been more clearly defined as "once guilt has been determined…"

And by then, doesn't most people have a vested interest in upholding the law?

Let me start by saying that this is my OPINION, and should not be taken as fact.

I DO believe that the foreman lied during voir dire, but whether he did consciously or not, I don't know. BUT, his omission does not signify an ax to grind with Samsung. Hell, I didn't know that Samsung even HAD a stake in Seagate. So, I don't believe that this fact alone is enough to grant a new trial.

On the other hand though, I do believe that his actions during the trial and deliberations (read his comments about his patent defense ideas) do point towards almost jury tampering. Probably not in an illegal way (threatening or paying jurors for specific verdicts) but tampering in how the jury saw the evidence that was presented them. This information colored the view of the jury which led to the whole uproar that this one juror has caused. This fact is why I believe that a new trial should be granted. Not that he had been sued by Seagate in the past, and not because he has a dubious patent awarded to him.

Again though, this is just my opinion on the matter, and could always be seeing this wrong.

First, as noted above, the "article" completely ignores that part of Samsung's filing which relates to Hogan's use of his own (incorrect) interpretation of patent law. Secondly, any comment in support of Samsung seems to attract negative votes.

He didn't answer as asked. He was asked "ever been involved" and later he said his omission was honest because the question was only the past 10 years. He lied.

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Yes, I forgot about the 10 year thing. I'm pretty sure in that transcript that I linked to, as well as other evidence put forth on Groklaw that Hogan's assertion that it only applies to 10 years is a total fabrication.

The meaty part of it is not that Hogan lied during Voir Dire, but that he incorrectly applied outside information that was harmful to the jury decision. Not only was his explanation of Prior Art factually inaccurate, but he was specifically instructed to only use the law as presented by the court.

Because that part is tangential to the real problem. The place where they're going to build their justification for appeal is in Hogan's perjury and the incorrectly completed verdict forms. What did or didn't go on behind closed doors while the jury deliberated cannot be challenged; only the ineligibility of a juror or a notably incorrect verdict. Typically the jury would be instructed by the judge to try again with the verdict form (amusingly enough, they were, delivering the same verdict minus a few bucks, which you can draw your own conclusions about).

In short, this one is basically guaranteed to be heard before the appeals court. Right now Samsung is just looking for it to be tossed out entirely so they can argue it from square one with a new judge, a new jury, and hopefully less problems. That's the ideal outcome for them and that Quinn Emmanuel is out there filing like madmen to accomplish it speaks volumes to why they're so highly respected and compensated.

I don't know how likely it is that someone would be biased against Samsung in this scenario (as there connection to Seagate is only tangential), but it does seem from the transcript that jurors were meant to list all cases for evidence of potential bias, even if it was explicitly stated "list all trials you've been in". I suppose it's conceivable he misunderstood, but maliciously or not, withholdng information from the court seems like a pretty big deal, so I'm leaning in favour of Samsung here.

Let me start by saying that this is my OPINION, and should not be taken as fact.

I DO believe that the foreman lied during voir dire, but whether he did consciously or not, I don't know. BUT, his omission does not signify an ax to grind with Samsung. Hell, I didn't know that Samsung even HAD a stake in Seagate. So, I don't believe that this fact alone is enough to grant a new trial.

On the other hand though, I do believe that his actions during the trial and deliberations (read his comments about his patent defense ideas) do point towards almost jury tampering. Probably not in an illegal way (threatening or paying jurors for specific verdicts) but tampering in how the jury saw the evidence that was presented them. This information colored the view of the jury which led to the whole uproar that this one juror has caused. This fact is why I believe that a new trial should be granted. Not that he had been sued by Seagate in the past, and not because he has a dubious patent awarded to him.

Again though, this is just my opinion on the matter, and could always be seeing this wrong.

Lying by omission is still lying, yes. I'm not so sure he had an axe to grind with Samsung (Seagate) as much as he really is, deep down, very pro-patent. The interviews seem to yell that to me. The judge asked the jury pool if anyone had strong feeling about patents and IP and this man did not speak up.

But no where in the questioning were the words "list all lawsuits you have been involved in." If the question doesn't ask for additional information, you don't give it. The question "have you ever been involved in" has the answer "yes." He didn't lie, he just didn't give the additional information that people thought he should have given despite the wording of the question.

"You, as jurors, are the judges of the facts. But in determining what actually happened–that is, in reaching your decision as to the facts–it is your sworn duty to follow all of the rules of law as I explain them to you.You have no right to disregard or give special attention to any one instruction, or to question the wisdom or correctness of any rule I may state to you. You must not substitute or follow your own notion or opinion as to what the law is or ought to be. It is your duty to apply the law as I explain it to you, regardless of the consequences. However, you should not read into these instructions, or anything else I may have said or done, any suggestion as to what your verdict should be. That is entirely up to you.It is also your duty to base your verdict solely upon the evidence, without prejudice or sympathy. That was the promise you made and the oath you took."

- That is the American Jurors Oath, read it and it will contradict your opinion. He took this oath, went against what he promised to do and now we are in this mess.

The meaty part of it is not that Hogan lied during Voir Dire, but that he incorrectly applied outside information that was harmful to the jury decision. Not only was his explanation of Prior Art factually inaccurate, but he was specifically instructed to only use the law as presented by the court.

Because that part is tangential to the real problem. The place where they're going to build their justification for appeal is in Hogan's perjury and the incorrectly completed verdict forms. What did or didn't go on behind closed doors while the jury deliberated cannot be challenged; only the ineligibility of a juror or a notably incorrect verdict. Typically the jury would be instructed by the judge to try again with the verdict form (amusingly enough, they were, delivering the same verdict minus a few bucks, which you can draw your own conclusions about).

In short, this one is basically guaranteed to be heard before the appeals court. Right now Samsung is just looking for it to be tossed out entirely so they can argue it from square one with a new judge, a new jury, and hopefully less problems. That's the ideal outcome for them and that Quinn Emmanuel is out there filing like madmen to accomplish it speaks volumes to why they're so highly respected and compensated.